It's easier than you might think. Not easy! But I've done it. Have Fortune <100 customers.

As others point out if you don't show your audit you have to affirm that you basically do everything an audit would check. So, do it.

I found Thoropass to be offer a deal that was affordable. You're not too small for them. Check them out.

You can form your processes any way you want! Use AI to construct your policies. Just document what you do.

I spent a probably 5 hours a month the first year. Learning curve and I felt I needed the hand holding from Thoropass... they were generous with time and explanations. Subsequent years, it's all set up, very little until audit time.